Question

Scenario:

John, a resident of the Philippines, was involved in a car accident in the United States while on vacation. The accident resulted in serious injuries to the other party involved. The injured party, David, who is a resident of Canada, decides to file a lawsuit against John for damages.

Based on the doctrine of Lex Loci Delicti, which refers to the law of the place where the wrong or harm occurred, the question arises as to which country's law should govern the determination of liability and damages in this case.

Discuss the following issues:

1. Under the principles of choice of law, how would you determine the applicable law in this case?
2. Explain the Doctrine of Renvoi and its possible application in this scenario.
3. Distinguish the Doctrine of Renvoi from the Doctrine of Processual Presumption.
4. Considering the circumstances of this case, which country's law is likely to be applied? Provide reasons to support your answer.